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State of Himachal Pradesh v. Rajesh Kumar @ Munnu

Criminal Appeal · 2025 INSC 331Decided 20 Feb 2025
Criminal Appeal No. 2097/2014
Justice Surya Kant · Justice Nongmeikapam Kotiswar Singh

Background

A young woman alleged that the respondent entered her house on the pretext of asking for a matchbox while her parents were away, and forcibly raped her. Based on this, the trial court convicted him under Sections 376 and 452 IPC and sentenced him to 10 years' rigorous imprisonment. The High Court of Himachal Pradesh later overturned the conviction and acquitted him, finding serious weaknesses in the prosecution's case, and the State appealed to the Supreme Court against that acquittal.

Decision Breakdown

The Supreme Court upheld the acquittal. It noted that both the complainant's mother and father gave evasive or even contradictory testimony (the mother turned hostile and denied the incident altogether), that there was an unexplained multi-day delay in lodging the FIR, and that the medical examination was inconclusive because the prosecutrix herself did not cooperate with it: a fact from which the Court drew a negative inference against the prosecution's version. Applying the well-settled principle that an appellate court should not disturb an acquittal unless the reasoning is perverse or based on a complete misreading of evidence, the Court found the High Court's analysis of the evidence to be careful and sound, and dismissed the State's appeal.

Lesson Learnt

In criminal appeals against an acquittal, the Supreme Court gives significant weight to a High Court's detailed re-examination of evidence and will not reverse it merely because a different view is possible: unexplained delay in filing an FIR and lack of cooperation with a medical examination can each seriously weaken a prosecution's case.

Official source (sci.gov.in)View Judgment (PDF)

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